CS Professional · IFSCA - Regulations, Listing and Compliances
Fund Management Services: formula sheet
Key formulas
- Regulator and statute
- IFSCA Act, 2019 → IFSCA → Fund Management Regulations → FME and schemes
- Use this chain to open any answer: statute gives power, regulator makes rules, rules bind the entity.
- Four building blocks
- FME + Scheme + Key persons + Ongoing compliance
- Every fund management answer should touch these four heads.
- Answer structure
- Provision → Facts → Analysis → Conclusion
- The written paper rewards this order, with drafting or compliance points added.
- Three FME categories
- Authorised FME | Registered FME (Non-Retail) | Registered FME (Retail)
- Know the three labels exactly. Retail is the category linked to schemes offered to the general public and carries the highest bar.
- Core entry test
- Category + eligibility + fit and proper + KMPs + net worth + fees = grant
- Use this as a checklist when answering any case on whether an applicant qualifies.
- Net worth rule
- Net worth required rises with the category and scope of activity
- Quote the exact amount only if you are sure of it from the current regulations. Otherwise state the principle and the schedule.
- Activity limit rule
- No FME may manage a scheme outside the permission of its category
- A lower category cannot take up activity reserved for a higher one without moving up.
- Core rule on people
- Authorisation or registration of FME = adequate capital + systems + qualified principal officer, compliance officer and KMP
- The people requirement is a condition of getting and keeping the status, not a one-time formality.
- Fit and proper test
- Eligible person = integrity + competence + financial soundness + no disqualifying record
- Apply it to the FME, its principal officer, compliance officer and KMP. Use the IFSCA fit and proper criteria as given in the Regulations.
- Principal officer
- Principal officer = senior accountable person + prescribed qualification + prescribed experience
- Quote the minimum qualification and years of experience exactly from the current Regulations in the exam.
- Compliance officer
- Compliance officer = monitor + report + advise + stay independent of investment decisions
- Independence is the point most often tested. State who the officer reports to and the duty to report violations to IFSCA.
- Replacement of KMP
- Vacancy or change in KMP → fill with eligible person + inform IFSCA as prescribed
- Check the time limit in the Regulations before quoting any number of days.
- Investor test
- Public or small investors → retail scheme | Accredited or large-ticket investors → restricted scheme
- This is the first filter in any question. Retail means stricter rules.
- Venture capital scheme test
- Restricted scheme + early-stage, unlisted, high-growth investee + usually closed-ended → venture capital scheme
- It is a type of restricted scheme. The investment focus decides the label, not the size of the fund. Restricted-scheme investor and placement conditions still apply.
- Family investment fund test
- Restricted scheme + single family as investors + run by a fund management entity → FIF
- Check who the investors are and whether they are related as one family, as the regulations define. Then apply the FIF conditions, such as minimum corpus and investor limit.
- Corpus and investor limits
- Minimum corpus + minimum investment per investor + maximum number of investors, as set for each scheme type
- Quote the figures from the current regulation text. If a question gives the figures, use them.
- Accredited investor
- Individual or entity meeting the prescribed net worth or income thresholds
- Accredited investors are usually exempt from the minimum per-investor ticket that applies to others in restricted schemes.
- Net Asset Value (NAV)
- NAV = Fair value of scheme assets − Liabilities (including accrued expenses)
- Assets include investments, cash and accrued income. Use fair value as per the valuation policy, not cost.
- NAV per unit
- NAV per unit = NAV ÷ Number of units outstanding
- Units are issued and redeemed at this price (plus or minus any permitted load or fee).
- Exposure to a single issuer
- Exposure % = Value of investment in the issuer ÷ NAV × 100
- Compare with the limit applicable to that scheme type. Calculate on NAV, not on the amount invested originally.
- Leverage ratio
- Leverage = Gross exposure ÷ NAV
- Gross exposure includes borrowed money and derivative positions. A ratio above 1 means the scheme is leveraged. Check the cap and disclosure rule for the scheme type.
- Core compliance rule
- Invest as per scheme documents + stay within diversification and leverage limits + value fairly under a written policy + disclose
- Use this four-part structure as the skeleton of any answer.
- Four-layer compliance map
- Conduct + Disclosure (placement memorandum) + Audit + Reporting to IFSCA, backed by Inspection and Penalty
- Use this as a checklist for any case question. Test each layer against the facts given.
- Placement memorandum rule
- Offer document must be true, adequate, and updated for material changes
- A material omission or misleading statement is a breach even if no investor has yet suffered a loss.
- Accountability rule
- FME is responsible for compliance; Compliance Officer monitors and reports
- Appointing a Compliance Officer does not remove the FME's own liability.
- Enforcement ladder
- Inspection → show-cause notice and hearing → direction / penalty / suspension or cancellation
- Name the steps in order. Do not jump to cancellation without notice and hearing.
Quick revision
- The IFSCA is the regulator for fund management in the IFSC, and the IFSCA (Fund Management) Regulations, 2022 are the main source.
- A fund management entity must be authorised or registered, depending on its category, before it manages funds.
- Know each entity category and what it is permitted to manage; do not treat them as interchangeable.
- A fund management entity must have the key managerial personnel the Regulations require and a compliance officer.
- The compliance officer is responsible for monitoring compliance and reporting issues; know the qualification and role conditions.
- Restricted schemes are meant for a limited class of investors, while retail schemes are open to the general investor and carry stricter conditions.
- Venture capital schemes have their own category with specific investment focus and conditions.
- Investment conditions and restrictions differ by scheme type; always identify the scheme first.
- Valuation must follow the method and frequency the Regulations and the scheme documents require.
- Continuing obligations include periodic reporting to IFSCA and disclosure to investors; track due dates.
- Answer cases in order: provision, facts, conclusion, then the practical compliance step.
- Verify thresholds and limits in the current text before quoting any figure.
Common mistakes
- Saying SEBI regulates funds set up in GIFT City IFSC. Fix: Anchor on the IFSCA Act, 2019. For IFSC activity, IFSCA is the primary regulator and its regulations apply.
- Treating the fund and the fund manager as the same thing. Fix: Define them separately. The manager is the entity authorised to run the business; the fund or scheme is the pool of investor money.
- Mixing up the three categories or using the old two-way split of authorised and registered only. Fix: Always write all three labels together and link retail to schemes for the general public.
- Quoting exact net worth or fee figures from memory. Fix: Quote a figure only if you are sure it is current. Otherwise state that net worth rises with category and is as specified in the regulations.
- Treating the compliance officer as part of the investment team Fix: Stress independence. The compliance officer must be able to challenge investment decisions, so flag any clash of roles in your answer.
- Quoting experience or qualification figures from memory Fix: State the principle and quote a figure only when you are sure of it from the current Regulations text. Never import SEBI numbers.
- Treating a restricted scheme as open to any investor. Fix: Write that a restricted scheme is privately placed to accredited or large-ticket investors only, with a cap on investors.
- Calling a scheme venture capital because it is large or risky. Fix: Define it by investment focus: early-stage, unlisted, high-growth businesses, normally closed-ended. Add that it is a type of restricted scheme, so the restricted-scheme investor and placement conditions apply.
- Applying one set of limits to all scheme types. Fix: Always name the scheme type first. Say that restricted schemes for accredited investors have more flexibility than retail schemes, and check the Regulations for the exact limit.
- Calculating exposure on the original amount raised instead of current NAV. Fix: Use current NAV as the denominator. Limits are tested against the scheme's current value.
Exam tips
- Open every answer with the chain: IFSCA Act, 2019, IFSCA, regulations, entity. It earns early marks.
- Use short headings in your own answer such as provision, analysis and conclusion, as the paper is case-based.
- Since electives are open book, mark the regulation definitions and authorisation conditions in your text so you can find them fast. Do not copy them word for word.
- Do not memorise section numbers you are unsure of. A correct plain-words rule scores better than a wrong number.
- Always end with practical compliance points: authorisation, key persons, valuation and reporting.
- Open every answer with the category, because marks follow the correct classification.
- Do not invent figures. If unsure of an amount, state the principle and refer to the schedule of the regulations.
- Use a short list for eligibility conditions. Examiners reward complete and orderly coverage.